Williams v. Reed
civil; unemployment claimants sued the state labor secretary in Alabama state court under § 1983 for an order to speed up processing of their benefits claims; trial court dismissed for failure to exhaust state administrative remedies; Alabama Supreme Court affirmed; certiorari granted; reversed and remanded (5-4) (result: remanded)
Facts
- 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
But according to Bateman, the Department never scheduled a hearing or otherwise acted on his appeal, even after he attempted to follow up by email and phone calls numerous times.
- 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
The claimants did not ask the court to rule that they were entitled to unemployment benefts.
- 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
In the unusual circumstances presented here— where a state court's application of a state exhaustion re- quirement in effect immunizes state offcials from § 1983 claims challenging delays in the administrative process— state courts may not deny those § 1983 claims on failure-to- exhaust grounds.
- 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
This Court has long held that “a state law that immunizes government conduct otherwise subject to suit under § 1983 is pre-empted, even where the federal civil rights litigation takes place in state court.”
- 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
Rather, a state rule runs afoul of Hay- wood if it operates as an “immunity statute cloaked in juris- dictional garb” by wholly barring a “particular species” of § 1983 suits in state court.
- 17 Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar not law
By affording immunity from those claims, the Ala- bama ruling contravenes this Court's § 1983 precedents.